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This provision identifies four Sub-Processors engaged specifically for HubSpot AI functionality: Amazon Web Services (hosting EEA-region AI processing), Google LLC (EEA-region AI processing), OpenAI (EEA and Switzerland AI processing), and Hyperdoc (meeting recordings and transcripts, with EU data center in Germany). All four are listed as feature-specific Sub-Processors applicable to the HubSpot AI service.
This analysis describes what HubSpot's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision discloses that Customer Data processed through HubSpot AI features, including meeting recordings and transcripts, may be accessed by OpenAI, Google LLC, Amazon Web Services, and Hyperdoc. The applicable service listed for all four is HubSpot AI, indicating that Customer Data input into or generated by AI-powered features may be processed by these external AI infrastructure providers across US and EEA data centers.
Interpretive note: The scope of Customer Data processed by AI Sub-Processors and the specific terms under which those Sub-Processors handle data (including model training exclusions or data retention limits) are not disclosed in this document and would require review of HubSpot's DPA and each Sub-Processor's data processing addendum.
Under this provision, Customer Data used in HubSpot AI features may be processed by OpenAI, Google LLC, Amazon Web Services, and Hyperdoc, including meeting recordings and transcripts handled by Hyperdoc with an EU data center in Germany. Customers who do not wish to have Customer Data processed by these AI Sub-Processors may choose not to use HubSpot AI features.
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"Amazon Web Services, Inc. AI Service Provider HubSpot AI United States European Economic Area regions United States United States ... Google LLC AI Service Provider HubSpot AI United States European Economic Area regions United States United States ... OpenAI, L.L.C. AI Service Provider HubSpot AI United States European Economic Area and Switzerland United States United States ... Hyperdoc, Inc. Meeting recordings and transcripts HubSpot AI United States Germany United States United StatesExcerpt from HubSpot's Sub-Processors
(1) REGULATORY LANDSCAPE: AI sub-processor disclosures engage GDPR Article 28 (sub-processor obligations), and may also engage obligations under the EU AI Act depending on how HubSpot's AI features are classified under that framework. Processing of meeting recordings and transcripts by Hyperdoc may involve special categories of personal data depending on content, implicating GDPR Article 9. Data transferred to OpenAI's US infrastructure from the EEA requires Standard Contractual Clauses or equivalent transfer mechanisms. The Irish Data Protection Commission and relevant national supervisory authorities have jurisdiction. The EU AI Act, with phased enforcement beginning in 2024-2026, may impose additional transparency and risk management obligations for AI systems processing personal data. (2) GOVERNANCE EXPOSURE: High. The use of four distinct AI Sub-Processors, including large language model providers (OpenAI, Google LLC), introduces data minimization, purpose limitation, and onward transfer considerations that standard sub-processor frameworks may not fully address. Meeting recordings and transcripts processed by Hyperdoc may contain personal data of third parties (meeting participants) who are not HubSpot customers, raising additional controller and processor obligation questions. (3) JURISDICTION FLAGS: EU and EEA customers face the highest exposure for AI sub-processor data flows, particularly for OpenAI's US-based processing and any HubSpot AI features not routed through EEA data centers. Customers in regulated sectors (healthcare, financial services, legal) should assess whether Customer Data input into HubSpot AI features may be subject to sector-specific restrictions on third-party AI processing. (4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should confirm the data processing agreements in place between HubSpot and each AI Sub-Processor, including data retention, model training, and onward transfer terms. OpenAI and Google LLC operate their own data processing addenda with varying terms; HubSpot's DPA obligations to customers may not fully flow down to the specific terms those Sub-Processors apply. Meeting recording and transcript data processed by Hyperdoc may require separate disclosure to meeting participants under applicable privacy laws. (5) COMPLIANCE CONSIDERATIONS: Teams should conduct a data protection impact assessment for HubSpot AI features if Customer Data processed includes personal data of EU residents. Records of processing activities should be updated to reflect AI Sub-Processors and applicable data flows. Customers should assess whether their end users or data subjects have been informed that their data may be processed by AI Sub-Processors, and whether any additional consent or notice obligations apply.
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This provision discloses that Customer Data processed through HubSpot AI features, including meeting recordings and transcripts, may be accessed by OpenAI, Google LLC, Amazon Web Services, and Hyperdoc. The applicable service listed for all four is HubSpot AI, indicating that Customer Data input into or generated by AI-powered features may be processed by these external AI infrastructure providers across US …
Under this provision, Customer Data used in HubSpot AI features may be processed by OpenAI, Google LLC, Amazon Web Services, and Hyperdoc, including meeting recordings and transcripts handled by Hyperdoc with an EU data center in Germany. Customers who do not wish to have Customer Data processed by these AI Sub-Processors may choose not to use HubSpot AI features.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by HubSpot.